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08 May 2020

Washington Dispatch for April 2020

The latest edition of Ernst & Young's Washington Dispatch is attached below. Prepared by Ernst & Young LLP's International Tax and Transaction Services group, this monthly newsletter summarizes recent developments in US international taxation. Highlights of this month's edition include:

Legislation

  • President Trump signs interim coronavirus relief measure; attention turns to COVID-19 bill #4 

IRS news

  • IRS issues final and proposed regulations on hybrid mismatches, DCLs and conduit financing; more certainty but some surprises
  • New anti-abuse rule targeting certain 'GILTI gap period' transactions included in proposed regulations on hybrid mismatch, dual consolidated loss, conduit financing and GILTI rules
  • Taxpayers need to consider international tax implications of making certain NOL elections under Revenue Procedure 2020-24
  • IRS issues FAQs on interaction of NOL carrybacks and Section 965 inclusions
  • IRS announces taxpayers can temporarily fax Forms 1139 and 1045 to claim NOL carrybacks and AMT credits under CARES Act
  • IRS provides relief for potential tax consequences caused by COVID-19 travel restrictions
  • IRS withdraws 2004 Notice on ‘Midco’ transactions

Transfer pricing news

  • IRS releases FAQs on transfer pricing documentation best practices
  • IRS issues annual APA report for 2019

OECD news

  • OECD BEPS 2.0 project to continue on current timelines
  • OECD Secretariat issues guidance on impact of the COVID-19 crisis on treaty-related issues
  • OECD releases second batch of Stage 2 peer review reports on dispute resolution 

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ATTACHMENT

Washington Dispatch for April 2020

Document ID: 2020-5700

 
 

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